Construction has long been recognized as a high hazard industry and is one of the
industries targeted in MOSH's Five Year Strategic Plan. The State
has experienced significant construction activity in recent years.
Accidents relating to falls from elevations are one of the leading
causes of serious injuries and fatalities. It is believed through
a local emphasis program that increases awareness and accelerates
enforcement activity, injuries can be reduced. It is also recognized
that a tracking mechanism for these type inspections would prove
beneficial in monitoring the area of fall hazards. In the past,
many unprogrammed inspections have been conducted through CSHO
self referrals, imminent danger complaints or through accident
investigations. This LEP is designed to increase inspection activity,
provide tracking, enhance expertise and formalize procedures.

Action:

MOSH compliance personnel shall ensure that the procedures contained in this directive are
followed when conducting this LEP. The Regional Offices will implement
the procedures described in section VIII of this Instruction in
response to imminent dangers or serious fall hazards that are
identified on construction sites. The Regional Supervisors shall
use the LEP as a basis for scheduling and conducting safety inspections
of construction sites. This LEP is intended to be used on any
construction site where fall hazards have been alleged and/or
identified to initiate safety inspections. These inspections may
be expanded to comprehensive inspections of multi employer construction
sites in accordance with the guidelines established in the FOM.

A. An inspection targeting system which encompasses identification of sites at
the beginning of the quarter and the random selection of sites
is not practical. Hazards related to falls on construction sites
are normally transient and of limited duration. This limits the
practicality of targeting the site in advance. Therefore, inspections
conducted under this LEP would be initiated by several means:
CSHO observance, non formal complaints, and referrals from other
outside sources.

B. All work sites where fall hazards are observed by compliance officers will be
selected for inspection under this LEP. These sites shall include
but shall not be limited to:

Structural steel erection where fall protection for employees other than ironworkers
is not apparent and potential falls or related hazards exist;

Structural steel erection where fall protection for ironworkers 10 feet or more
above a lower level (in excess of 30' or two stories, whichever
is less for employees working in controlled decking zones, and
in excess of 30 feet for connectors) is not apparent and potential
falls or related hazards exist;

Sites where fall protection for employees on scaffolds more than 10 feet above
a lower level is not apparent;

Sites where fall protection for employees on walking/working surfaces 6 feet
or more above a lower level is not apparent;

Other activities which constitute potential falls and no protective systems are
in use such as erection of tanks, communication and broadcast
towers, certain work on cranes and derricks, and activities
where employees are working from elevations without fall protection.

When a job site with fall hazards is noted during travel, the CSHO will notify the
supervisor with the name of the contractor (if known) and the
location of the site. The supervisor will determine if the site
has been inspected within the last 30 days. If the site has not
been inspected within the last 30 days, permission will be given
to inspect the site. If the site has been inspected within the
last 30 days, an inspection will be authorized only if an imminent
danger appears to be present, or at the Regional Supervisor's
discretion. These inspections will normally be limited to the
imminent danger situation and plain view items. The CSHO will
remain at the site to observe the abatement procedures and/or
to assist with abatement methods. CSHOs will record these inspections as referral inspections.

C. A large number of fall hazards are reported via referrals and complaints, both
of a formal and a non formal nature. Formal complaints of fall
hazards on construction sites will continue to be scheduled before
programmed inspections. Non formal complaints and referrals which
would normally be handled by letters will be handled in accordance
with paragraph VIII.B. above. Inspection history and the scope
of the inspection will be handled in the same manner.

II. Recording in IMIS.

The IMIS identifier code to be used in item 25c on the OSHA-1 will be "FALL
HAZARDS IN CONSTRUCTION".